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    <title>2014 (11) TMI 1 - ITAT COCHIN</title>
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    <description>Section 40(a)(ia) was interpreted to apply not only to sums outstanding as payable at year-end but also to amounts already paid during the year where tax was deductible at source and was not deducted or paid. The Tribunal preferred the reasoning of the Calcutta and Gujarat High Courts and rejected the narrower view that the word &quot;payable&quot; limits disallowance to year-end liabilities. It also held that a bare dismissal of an SLP does not declare law under Article 141.</description>
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      <link>https://www.taxtmi.com/caselaws?id=252684</link>
      <description>Section 40(a)(ia) was interpreted to apply not only to sums outstanding as payable at year-end but also to amounts already paid during the year where tax was deductible at source and was not deducted or paid. The Tribunal preferred the reasoning of the Calcutta and Gujarat High Courts and rejected the narrower view that the word &quot;payable&quot; limits disallowance to year-end liabilities. It also held that a bare dismissal of an SLP does not declare law under Article 141.</description>
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